What a battery passport costs, and what missing one costs

Budgets for the battery passport often start with software. That's usually the smallest line.

Where the money goes

• Initial data collection. Usually the largest block. The data is scattered across cell suppliers, internal systems (ERP, PLM, lab, quality) and partners, and most of the cost is people chasing and checking it.
• People. A project lead at roughly 20 to 40% of a full-time role during set-up and 10 to 20% after, plus part-time input from purchasing, engineering, quality and IT, and someone who can do the carbon calculation.
• Specialist help. Optional, but common for the life cycle assessment, due diligence and interpreting the regulation.
• Software and hosting. A subscription or an in-house build (see below).
• Things outside the software. GS1 identifiers (a GTIN per model, a GLN for the company), durable QR marking on the line, a qualified electronic seal for the registry, conformity assessment fees and supply-chain data collection.
• Upkeep. New variants, data updates, changing standards and recycled-content documentation.

What moves the total: the battery type (and so how many fields are mandatory), how organised your data already is, how many suppliers have to provide material data, and production volume, since identifiers and conformity assessment are largely fixed and weigh more heavily on small producers.

Compare like with like. The first year carries the data collection, coordination and any consulting; later years mainly carry software, upkeep and new models. Quoting only one of those misstates the cost. For conformity assessment, a self-declared module costs internal effort, while a notified-body module brings recurring surveillance, not a single audit.

Build, extend or subscribe

Option	Set-up	Suits
In-house build	6 to 18 months, high initial cost, a team to maintain it	Large companies with their own IT and unusual needs
Extend the ERP	High integration cost, long timelines, tied to the ERP vendor	Companies already deep in one platform
Specialist software	Low entry cost, quick start, the provider tracks the standards	Most manufacturers and importers

Whichever you choose, insist on full data export, and on the QR code's address staying under your control.

Why spreadsheets don't hold up

Spreadsheets are where most passport projects start, and that's fine for a gap analysis. As the record itself, they fall short:

• they don't check types, mandatory fields or value ranges, so errors appear at export or audit;
• every team and supplier builds its own layout, so combining them is manual;
• they don't record who changed what, or when;
• they can't produce valid structured data, QR codes or the access levels the regulation requires;
• they're built per model, while the regulation needs one record per physical battery.

A governed record needs the DIN DKE SPEC 99100 structure built in, validation when data is entered, versions and a change history, field-level access, an audit log including supplier submissions, structured export and an interface to your other systems, identifiers that meet ISO/IEC 15459, and stable addresses behind the QR codes.

To move across: list where the data lives, run the gap analysis, choose a tool, build one complete battery by hand, import the rest, test serial numbers at volume with a small batch, and scan a real printed label with an ordinary phone before you print in bulk.

What missing it costs

From 18 February 2027, a covered battery without a valid passport can't be placed on the EU market. That alone is the main risk: lost sales, held shipments and missed delivery dates with OEM customers, often with contractual penalties.

On top of that, member states set the penalties (Art. 93), and they vary:

• Germany has three tiers: up to €500,000 for due diligence breaches, up to €100,000 for missing producer registration and ignoring corrective orders, and up to €10,000 for everything else, including incomplete, inaccurate or outdated passport data and missing labels or QR codes. A fine can exceed the tier maximum to remove any economic advantage gained.
• France treats breaches as fifth-class offences under the consumer code, with fines up to €1,500 (€3,000 for repeat offences) and a multiplier for companies.

Authorities can also order withdrawal from every sales channel, including online marketplaces, recall batteries already sold, ban sales temporarily or for good, and confiscate stock. Customs can hold non-compliant batteries at the border. Violations are shared between member states, so a problem found in one country can prompt checks in others. Based on similar EU rules, expect enforcement to start with guidance and tighten within 12 to 18 months, not a grace period.

FAQ

What is the biggest cost of a battery passport?

Usually the initial data collection: gathering, checking and structuring data from suppliers and internal systems. Software is often the smallest part of the budget.

Can we manage battery passports in a spreadsheet?

Not as the record itself. Spreadsheets don't validate data, track changes, control access by level or produce one record per battery. They are fine for an initial gap analysis.

What happens if a battery has no passport after February 2027?

It can't be placed on the EU market. Member states can also fine, order withdrawals or recalls, and customs can hold shipments at the border.

Sources

• Battery passport costs, DPP Hero
• Battery passport penalties for non-compliance, DPP Hero
• From Excel to battery passport, DPP Hero